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‘It’s a natural’: How should the FDA define natural?

Public requests definition for common food marketing term

By Bernie Pacyniak
December 16, 2015

We’ve all heard the saying, “He/she is a natural.”  Many of you probably recall the movie, “The Natural” starring Robert Redford, which was based on the 1952 Bernard Malamud novel. If you’re a natural at something, it means doing whatever it is you do comes easily, or at least seems to.

But it’s not “a natural” for the Food and Drug Administration to define natural in food labeling. In fact, the agency has long stayed away from that challenge, simply stating that the term “natural” means that nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in that food.

Last month, however, the FDA issued a request for comments on use of the term “natural” on food labeling. Why the change of heart? Well, I’ll let the FDA explain:

“Because of the changing landscape of food ingredients and production, and in direct response to consumers who have requested that the FDA explore the use of the term "natural," the agency is asking the public to provide information and comments on the use of this term in the labeling of human food products.

The FDA is taking this action in part because it received three Citizen Petitions asking that the agency define the term “natural” for use in food labeling and one Citizen Petition asking that the agency prohibit the term “natural” on food labels.  We also note that some Federal courts, as a result of litigation between private parties, have requested administrative determinations from the FDA regarding whether food products containing ingredients produced using genetic engineering or foods containing high fructose corn syrup may be labeled as "natural."

Although the FDA has not engaged in rule making to establish a formal definition for the term "natural," we do have a longstanding policy concerning the use of “natural” in human food labeling.  However, this policy was not intended to address food production methods, such as the use of pesticides, nor did it explicitly address food processing or manufacturing methods, such as thermal technologies, pasteurization, or irradiation. The FDA also did not consider whether the term "natural" should describe any nutritional or other health benefit.”

As it explains, it’s asking the public and industry to determine whether it should define “natural” and if so, how and what it would mean for food labeling. The comment period began Nov. 12 and extends through Feb. 10, 2016.

So I started thinking about this. And heck, it’s not easy, although you would think that intuitively, all of us know what natural is. But it’s a bit more complicated. So, as the FDA notes, does pasteurizing make milk not “natural”? Or what about an ingredient that’s natural to begin with, but by processing it we’ve given it a slightly different characteristic? Again, as the FDA points out, there’s been litigation questioning whether high fructose corn syrup is “natural.”

My initial response to both those questions is yes. After all, pasteurizing keeps milk safe. As for HFCS, the process involves using a yeast-based enzyme. I’m OK with that, considering how integral yeast is to baking. That’s a natural process, right?

But I know there are some who might take issue. And that’s all right, since I really believe it’s important to set a standard. Remember the whole chocolate identity battle? Aren’t we all glad that there are strict rules to making chocolate here in the United States?

So I urge everyone to let the FDA know they should take this on. It would provide a level playing field for all, even those who are “naturals.”

KEYWORDS: FDA natural candy

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With more than 30 years experience in B-to-B reporting, writing and editing — the bulk of which was dedicated to covering the bakery, confectionery and snack industries — Pacyniak has chronicled changes within the food industry since the early 1980s. A Boston University journalism degree graduate, he worked for a variety of publications before joining BNP Media in 1994 as editor of Snack Food & Wholesale Bakery magazine. In 2001, he took over as editor-in-chief of Candy Industry until 2018.

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